HRS DOCUMENTATION RECORD — REVIEW COVER SHEET

Name of Site: 

### Wright Chemical Corp.

NCD 024 766 719

Contact Persons: U.S. Environmental Protection Agency, Region 4: (Name) (Telephone)

Jennifer Wendel NPL Coordinator (404) 562-8799

North Carolina Department of Environment and Natural Resources:

Site Investigation: (Name) (Telephone) Jeanette Stanley (919) 508-8453

Documentation Record: Jeanette Stanley (919) 508-8453

Pathways, Components, or Threats Not Scored:

Ground Water Migration Pathway The ground water pathway was not scored because scoring the ground water pathway would have a minimal impact on the site score.

Surface Water Drinking Water threat/targets The drinking water threat was not scor ed because there is no drinking water

intake within the 15-mile surface wa ter pathway downstream of the site.

Surface Water Environmental Threat Environmental targets/threats were no t scored because scoring the observed release to the fishery almost maximized th e pathway score. The addition of the

surface water environmental threat scor e would have minimal impact on site

score.

Soil Exposure Pathway The soil exposure pathway was not scored because the soil exposure pathway has a minimal impact on the overall site score.

Air Migration Pathway The air pathway was not scored because scoring the air pathway would have a minimal impact on the site score.HRS DOCUMENTATION RECORD

Name of Site: Wright Chemical Corp.

EPA Region: 4

Date Prepared: March 2010

Street Address of Site*: State Rd. 1878

City, County, State, and ZIP: Ri egelwood, Columbus County, NC 28456

General Location in the State: Coastal Plain

Topographic Map: Acme

Latitude*: 34.3284 o north latitude

Longitude*: 78.2051 o west longitude Location is approximate center of denuded area (Source 1) (Ref. 4, pp. 1, 105, 106; Figs. 1, 4)

Scores

Air Pathway — Not Scored Ground Water Pathway — Not Scored Soil Exposure Pathway — Not Scored Surface Water Pathway — 96.06

HRS SITE SCORE



### 48.03

* The street address, coordinates, and contaminant locati ons presented in this HRS documentation record identify the general area the site is located. They represent one or more locations EPA considers to be part of the site based on the screening inform ation EPA used to evaluate the site for NPL listing. EPA lists national prior ities among the known “releases or threatened releases” of hazardous substances; thus, the focus is on the release, not precisely delineated boundaries. A site is defined as where a hazardous substance has been “deposited, stored, placed, or otherwise come to be located.” Generally, HRS scoring a nd the subsequent listing of a release merely represent the initial determination that a certain area may need to be addressed under CERCLA. Accordingly, EPA contemplates that the preliminary description of facility boundaries at the time of scoring will be refined as more information is developed as to where the contamin ation has come to be located.

1WORKSHEET FOR SITE SCORE

S S 2

1. Ground Water Migration Pathway Sc ore Not Scored Not Scored

2a. Surface Water Overland/Flood Migration --

Drinking Water Threat Not Scored Not Scored

Food Chain Threat 96.06 9227.52

Environmental Threat Not Scored Not Scored

Surface Water Overland/Flood Migration Component (subject to maximum value of 100, Ref. 1, Section 4.1.5) 96.06 9227.52

3. Soil Exposure Pathway Score Not Scored Not Scored

4. Air Migration Pathway Score Not Scored Not Scored

5. Total of S gw 2 + S

sw 2 + S

s 2 + S

a 2 = 9,227.52

6. HRS Site Score: Value on line 5. divided by four,
then take the square root 

### 48.03

2WRIGHT CHEMICAL CORP. RIEGELWOOD, COLUMBUS COUNTY, NC

LIST OF FIGURES

1. US Geological Survey, Acme T opographic Quadrangle Map, 1984

2. Sanborn Fire Insurance Map, 1889

3. Sanborn Fire Insurance Map, 1910

4. Source Detail Area with Wetland Boundaries

5. Oak Bark Holdings

6. Livingston Creek and Cape Fear River

7. 2007 ESI Sample Location Map

8. Wetlands

9. Acme, NC Wetland Inventory Map

LI ST OF TABLES

1. Source Soil and Background Soil Samples

2. Source Soil and Background Soil Results

3. Background Sediment Samples

4. Background Sediment Sample Results

5. Sediment Samples

6. Sediment Sample Results

7. Source 1 Contaminants Documented in Observ ed Release to Sediment in the Fishery

8. Source 1 Contaminants Documented in S ource with Containment Factor of 10, not documented in Observed Release to Fishery Sediment

3WR IGHT CHEMICAL CORP. RIEGELWOOD, COLUMBUS COUNTY, NC

LI ST OF REFERENCES

1. US Environmental Protection Agency, Hazard Ranking System, Final Rule, 55 FR 51532, 1990. http://www.epa.gov/superfund/sites/ npl/hrsres/index.htm#HRS%20Rule . Table of Contents and Sections 1 – 6. Excerpt. 75 pages. A complete copy of the Hazard Ranking System document is available in the Region 4 Docket.

2. US Environmental Protection Agency, S uperfund Chemical Data Matrix (SCDM). Office of Solid Waste and Emergency Re sponse. Directive 9345.1-13. 2004. Appendix BI. Excerpt. 15 pages. A complete copy of SCDM is available at http://www.epa.gov/superfund/site s/npl/hrsres/tools/scdm.htm

,

3. US Geological Survey, 7.5-minute (1:24,000) topographic quadrangle maps of North Carolina; Acme, NC, 1984; point Caswell, NC, 1997; and Freema n, NC, 1986. 3 maps merged and modified into one show ing radii and target information.

4. Expanded Site Inspection, Wright Chem ical Corp. Site, NCD 024 766 719, Riegelwood, Columbus Co., NC, Jeanette Stanley, NC Superfund Section, May 30, 2008. 579 pages.

5. US EPA, Office of Solid Waste and Em ergency Response, Multi-Media, MultiConcentration, Inorganic Analytical Servi ce for Superfund (ILM05.3), February 2004. 4

pages.

6 US EPA, Office of Solid Waste and Emergency Response, Multi-Media, Multi- Concentration, Organic Analytical Se rvice for Superfund (SOM01.1), January 2006. 6 p ages.

7. Stanley, Jeanette S., Chemist, NC Superf und Section, Memo to File, December 9, 2009. SUBJECT: Source of base maps and elements for Figures 4 – 9. 1 page.

8. Stanley, Jeanette S., Chemist, NC Superf und Section, Memos (2) to File, December 17, 2009 and December 18, 2009. Bateson, James, Environmental Engineering Supervisor, NC Superfund Section, Memo to File, January 29, 2010 8 pages.

9. Parker, Stuart F. Geologist, NC Superfund Section, Kaiser Acme Farmarket Site ReAssessment Report, August 13, 2004. 12 pages.

10. Pettergarrett, Stephanie, Environmental Sc ientist, NC DENR Wa ter Quality Section, email correspondence with Jeanette St anley, December 17, 2009. 2 pages.

4Site: Wright Chemical Corp.

NCD 024 766 719 Date: 02/12/08

Columbus Co., NC Drawn By: JSS Scale: As Shown

Figure 2: Sanborn Fire Insurance Map, 1889 0 50 100

SOURCE: Sanborn Fire Insurance M aps, Wilmington, NC, sheet 16, 1889 0 200

FEETSite: Wright Chemical Corp.

NCD 024 766 719 Date: 02/12/08

Columbus Co., NC Drawn By: JSS Scale: As Shown

Figure 3: Sanborn Fire Insurance Map, 1910 Lead Acid Chambers Sulphur Bins Burner House

Iron Burners

Acid Chambers

SOURCE: Sanborn Fire Insurance M aps, Wilmington, NC, sheet 34, 1910 0 200

FEETSite:WrightChemicalCorp.NCD024766719SeeRef.7ofHRSDocRecordforfiguresourceinformationDate:01/27/2010ColumbusCo.,NCDrawnBy:JTB

K ai s e r A gr i c u l tu r al (

a r c h i ve d )AerialPhotodate2007Figure4:SourceAreaDetailwithWetlandBoundaries~200’SoilSampleSedimentSampleAreaofformerLeadChambers L i v i n g s to

n C reekWC‐012‐SSWC‐011‐SSWC‐013‐SSWC‐003/103‐SDWC‐004‐SDPPE M il l C r e e kWC‐010‐SDPUBHPUBHhPUBHPUBHPUBHPUBHhPUBHR2UBHPFO1APFO1/2FPFO1/2FPFO1/2FPUBHNWIClassFigure 5: Oak Bark HoldingsSite: Wright Chemical Corp.NCD 024 766719Date: 02/12/08; rev. 12/09/09Columbus Co., NCDrawn By: JSS739.9Total17.65OAK BARK CORPORATION137.8OAK BARK CORPORATION24.15OAK BARK CORPORATION58.58OAK BARK CORPORATION60.47OAK BARK CORPORATION15OAK BARK CORPORATION34OAK BARK CORPORATION0.95OAK BARK CORPORATION21.99OAK BARK CORPORATION145OAK BARK CORPORATION78.54OAK BARK CORPORATION81OAK BARK CORPORATION37.62OAK BARK CORPORATION3.53OAK BARK CORPORATION23.61OAK BARK CORPORATIONACRESOWNEROak Bark properties shownin yellow (color) or mediumgrey (black & white)Aerial Photo date - 2007Lead chamber areaHexionInternational Paper,aka Federal Paper Board~ 1⁄2 mileEllington, formerKaiser Acme FarmarketSee Ref. 7 of HRS Doc Recordfor figure source informationFigure 6: Livingston Creek and Cape Fear RiverSite: Wright Chemical Corp.NCD 024 766719Date: 05/21/08; rev. 12/09/09Columbus Co., NCDrawn By: JSSAerial Photo Date: 2004International PaperWright Chemical

C a p e F e a r Ri v e rLCV2LCV (pre-2005)~ 1⁄2 mileHoltrachem

M i l l C r e e kSee Ref. 7 of HRS Doc Record for figure source informationFigure 7: 2007 ESI Sample Location MapSite: Wright Chemical Corp.NCD 024 766719Date: 03/27/08; rev. 12/08/09Columbus Co., NCDrawn By: JSS / HZSedimentSamplesSoilSamples12765101498123

L i v i n g s t o n C r e e k Ra il r o a d N e i l s E dd y R d

G

a s P i p e l i n e

a n d

R

o a d

O l d

H

w

y 8 7

L i vi ng st on C r ee k~500’411 13Aerial Photo Date:

M i l l C re e kSee Ref. 7of HRS DocRecord forfigure sourceinformationFigure 8: WetlandsSite: Wright Chemical Corp.NCD 024 766719Date: 02/12/08; rev. 12/09/09Columbus Co., NCDrawn By: JSSAerial Photo date - 2007~500’See Ref. 7of HRS DocRecord forfigure sourceinformationSee Ref. 7of HRS DocRecord forfigure sourceinformation2.0 Site Description

Wright Chemical Corp is located in Colum bus County, NC in an industrial / rural area. The facility and Riegelwood are served potable water by a surface water intake on the Cape Fear River upstream of the site (Ref. 4, pp. 128; Fig. 1) . This area of Columbus County is the home of several large industria l facilities surrounded by residential properties, agricultural fields and wetlands. The portion of the facility being evaluated drains to Livingston Creek and subsequently to the Cape Fear River (Ref. 7, p. 1, Figs. 1, 4, 6, 8, 9).

The original business on the Wright Chemical Corp. property was Acme Chemical.

Acme Chemical was a fertilizer and sulfuric ac id manufacturing facility founded in 1883 (Ref. 4, pp. 244, 401; Figs. 2, 3) and was a family-owned company for four generations (Ref. 4, p. 401). The original Acme sulfuric acid plant was a le ad-lined “chamber-process” plant which thermally extracted sulfur from pyrite. Pyrite ore commonl y contains traces of arsenic, selenium, nickel, cobalt, and thallium. (Ref. 4, pp. 109, 186). “Lead Acid Chambers” are marked on the 1898 and 1910 Sanborn Fire Insurance maps (Ref. 4, pp. 173- 179; Fig 3). A comparison of early Sanborn Fire Insurance Maps with 1961, 1965, 1994, 2004 and 2007 aerial photographs confirms the location of the lead chambers (Ref. 4 pp. 115-117; Figs. 2, 3, 4, 5).

The second acid plant on the Wright Chemi cal Corp facility property was a “contactprocess” plant, which metal-catalyzed a refi ned sulfur feedstock. However, due to the corrosivity of sulfuric acid, lead-lined components were typically used in both processes (Ref. 4, pp. 109, 115-117, 161-162). Wright Chemical cons tructed several surface impoundments on the northern property during the 1970s (Ref. 4, pp. 109, 117, 120, 128). Acid manufacturing occurred on this property until 1991, and the build ings have since been demolished (Ref. 4, p. 109; Ref. 8, pp. 3-5). The Wright Chemical Corp facility property was sold to Oak Bark Corporation in 2004 (Ref.4, pp. 397, 453, 454).

The Wright Chemical Corp. site contains denuded, magenta- colored soil primarily on two parcels totaling about 80 acres (Ref. 4, pp. 29-32, 88, 92, 115, 116, 453, 454; Ref. 8, pp. 3-8; Figs. 4, 5). Aerial photos indica te stressed or absent vegetation extending to the creek channel (Ref. 4, pp. 109, 115-117, 180-182; Fig. 4). The mage nta soil coloration is characteristic of

former lead chamber sulfuric acid manufact uring facilities (Ref. 4, pp. 215). Primary contaminants are lead and arsenic, but numerous other inorganics and some pesticides were detected in this area of denuded magenta colore d soil (Ref. 4, pp. 72-81, 215; Ref. 9, pp. 1-12).

The HRS score is based on one source -- denuded , contaminated soil, and a release of site contaminants to sediment in the fishery. While there are extensive wetlands along the surface water pathway (Ref. 7. p. 1; Fig. 9), the environmen tal threat was not scored because it does not make a significant additional contribution to the s ite score. Samples used for this documentation were collected on April 10, 2007 and were collec ted according to the Sampling and Analysis Plan and Quality Assurance Project Plan (SAP/QAPP) (Ref. 4, pp. 99–104).

14SD -Character ization and Containment

Source No.: 1

SOURCE DESCRIPTION

2.2 Source Characterization

Number of the Source: 1

Name and description of the source :

In the 1880s, Acme Manufacturing began opera ting a lead chamber sulfuric acid and fertilizer manufacturing facility on the property, which operated until the 1960s or 1970s (Ref. 4, pp. 3, 9, 10, 108, 109, 173 – 179, 244). The Wright Chemical Corp. facility includes an area of stressed vegetation and magenta-colore d soil (Ref. 4, pp. 3, 88, 92, 116, 117; Fig. 4)

characteristic of former lead chamber sulfur ic acid manufacturing f acilities (Ref. 4, pp. 213 - 215). This magenta-colored soil is primarily on two parcels totaling about 80 acres owned by Oak Bark Corporation (Ref. 4, pp. 453, 454; Figs. 4, 5). A comparison of an early Sanborn Fire Insurance Map with recent aeria l photography confirms the former lead chambers location (Ref. 4, pp. 4 – 7, 173 – 179; Figs. 2, 3, 4, 5). Numerous other chemical operations have been and continue to be conducted on adjacent property (R ef. 4, pp. 9, 10); however, the focus of this documentation record is the past lead cham ber sulfuric acid manufacturing facility.

HRS Source Type: Contaminated Soil

The source is contaminated soil as de fined by samples WC-011-SS, WC-012-SS and WC-013-SS documented in the Table 1. These samples were collected near the former lead chambers and in the area where both 1) waste ma terials were placed and 2) overland flow from the former lead/acid chambers on the facility wa s received (Ref. 8, p. 7; Fig. 4). This area of denuded soil has a purplish/magenta coloration and appears fairly consistent between the three samples (Ref. 8, pp. 1, 3-5). This area remains unfenced and is outside any runoff control features. (Ref. 8, pp. 1, 3-5) It is accessible but there are no signs of recreation. (Ref. 8, pp. 1, 3- 5)

The source area was observed to consist of th ree contiguous subareas. These areas are, from south to north: Area a) an upland area of denuded soils where the former lead chambers had been located, Area b) a wooded slope covered at least in part with bulldozed material similar to

that observed in the former lead chamber area a), and Area c) a lowland area of contaminated soils. Source soil sample WC-012-SS was collected from Area a) while source soil samples

WC-011-SS and WC-013-SS were co llected from Area c), which ex tends to the probable point of entry (PPE) into Livingston Creek, and coinci des, generally, with an area classified as nonHRS qualifying wetland type PU BH (Ref. 8, p. 7; Fig. 4).

Area a) was void of vegetation and generally flat, with a discontinuous low berm on its northern edge. Parts of the flat areas and all of the berm area contained bricks, bits of wood, concrete and mortar, and pieces of clinker or slag . Soils in this area were of a magenta color

characteristic of lead contaminated soils obs erved by NC Superfund and EPA project staff at

15SD -Characterizati on and Containment

Source No.: 1

similar phosphate fertilizer site s under CERCLA assessment or reme diation in the southeastern United States (Ref. 8, p. 7; Fig. 4).

Area b) borders area a) and is sloped to the north, toward the floodplain of Livingston

Creek. Debris and soil similar to that observed in the berm above was visible on parts of the slope. The slope is traversed by a roadbed lead ing west-northwest down to the floodplain. The slope is not wooded on the east-northeast side of th is road. The shadow line of the woods makes the road location visible on Figure 4, located midway between sample locations WC-011-SS and WC-012-SS (Ref. 8, p. 7; Fig. 4). However, ther e were no samples collected from this area to confirm the presence of site hazardous substances.

Area c) contains a roughly circular area completely devoid of vegetation, approximately 200 feet across, visible on Figure 4 as a lighter colored area ex tending northwest from samples WC-011-SS and WC-013-SS. The lighter colore d ground appeared to cons ist of a number of overlapping or coalescing low waste piles. The material consists of a mix of these larger fragments with magenta colored sand and clay-siz ed material. It appe ars this material was

trucked down the road and du mped in place (Ref. 8, p. 7).

Location of the source, with re ference to a map of the site : North of railroad tracks and west of chem ical manufacturing fac ility (Figs. 1, 4, 7)

Containment

Release via overland migration and/or flood — Contaminated soil is outside any controlled runoff feature and is available for continuous and ongoing overland flow (Ref. 1, Table 4-2; Ref. 8, pp 1. 3-5).

An observed release of site contaminants to Livingston Creek (Ref. 1; Ref. 4, pp. 34, 36, 41, 47, 65, 66; Table 4-9)

Containment factor: 10

16SD-Hazardous Substances Source No.: 1 (Contaminated soil)

2.4.1 Hazardous Substances

On April 10, 2007 NC Superfund Section collect ed three source surface soil samples and one background surface soil sample, as summarized in Tables 1 and 2 below (Fig. 4). Samples were collected according to the Sampling and Analysis Quality Assurance Project Plan (SAP/QAPP) (Ref. 4, pp. 99-104), which was devel oped in accordance w ith the NC Superfund Section Quality Assurance Program Plan (QAPP) and Quality Assurance Standard Operating Procedures (QASOP). The QASOP adopts by reference the Field Branches Quality System and Technical Procedures, U. S. Environmental Prot ection Agency, Region 4. The Program Plan is derived directly from the EPA-Approved NC Department of Environmental and Natural Resources QA Plan for Data, 2004 (Ref. 4, pp. 99- 104). Samples were sh ipped to a Contract Laboratory Program (CLP) laborator y (A4 Scientific) and analyzed for total metals by ICP-AES and cyanide analysis by Statem ent of Work (SOW) ILM05.3 and they were analyzed for pesticides per method SOM01.1 (Ref. 4, pp. 34; Re fs. 5, pp. 2-4; Ref. 6, pp. 1-6). A US EPA Region 4 Science and Ecosystem Support Division Quality Assurance Chemist reviewed and validated this data for performance according to the Statement of Work (Ref. 4, pp. 33, 34, 67- 69).

The depths of the background and source soil samples were all similar (Table 1). The

source area was observed to be denuded and the leve l of contamination in the source area likely prevented growth of any vegetation for year s (Refs. 8, pp. 1, 3-5). The purple/magenta coloration in the source sample s is indicative of the lead / arsenic contamination (Ref. 4, pp. 215). Tables 1 and 3 contain summary of fi eld observations and references to these

observations.

17SD-Hazardous Substances Source No.: 1 (Contaminated soil)

Table 1. Source Soil and Background Soil Samples

Source Samples Date; Time Description

Surface soil sample (0-9”) in denuded area in a wetland with purple soils. Purple sand was encountered until 2”

– 6” when wet sand was found WC-011-SS 4/10/07; 1410 (Ref. 4, pp. 35, 70, 88, 92, 95, 97) (Ref. 4, pp. 88, 92; Fig. 7)

WC-012-SS 4/10/07; 1345 (Ref. 4, pp. 35, 70, 88, 92, 96, 98) Surface soil sample (0-9”) collected on top level by plant area. Purple soils encountered. (Ref. 4, pp. 88, 92; Fig. 7)

WC-013-SS 4/10/07; 1420 (Ref. 4, pp, 35, 70, 88, 93, 96, 98) Surface soil sample (0-6”) in area of purple soil in wetland area. All purple sand. (Ref. 4, pp. 88, 93; Fig. 7) Background surface soil (0-9”), Root & organics (0 – 3”, silty sand 3 – 6”, fine sandy loam 6 – 9”. Refusal at 9” WC-014-SS 4/10/07; 1200 (Ref. 4, pp. 35, 70, 87, 91, 96, 98) (Ref. 4, pp. 87, 91; Fig. 7)

18SD-Hazardous Substances Source No.: 1 (Contaminated soil) Table 2. Source Soil and Background Soil Results

Units mg/kg CRQL WC-011-SS WC-012-SS WC-013-SS WC-014-SS* (Background)

(Ref. 5) Ref. 4, pp. 34, 36, 57, Ref. 4, pp. 34, 36, 59 Ref. 4, pp. 34, 36, 61, 62 Ref. 4, pp. 34, 36,

63

Antimony** 6 69 J [34.8] 63 J [31.8] 86 J [43.4] 8.3 UJ (8.3 U)

Arsenic** 1 430 J [247] 700 J [402] 900 J [517] 1.4 J*

Cadmium 0.5 42 31 40 0.69 U Copper** 2.5 210 J [172] 720 J [590] 890 J [730] 1.9 J* (3.5 U)

Lead** 1 3500 J [2430] 7800 J [5417] 10000 J [6944] 16 J [23] Manganese 1.5 32 27 27 8.9

Mercury 0.1 2.4 2.4 35 0.056 J* (0.50 U)

Nickel 4 20 17 19 1.9 J* (5.5 U)

Silver 1 18 29 43 1.4 U

Thallium 2.5 16 22 28 3.5 U

Zinc 6 7500 4700 6700 14 J

J = estimated value “U” indicates non-detect. The number adjacent to the “U” or inside () is the MRL. [ ] provides the adjusted value for the estimated (J’d) value as ad justed for bias (Ref. 4, pp. 266 - 283). *( ) = Minimum Reporting Limit (MRL) is shown in parentheses when a trace va lue is reported below the MRL. The MRL is the analyte concentration which corresponds to the lowest quantitative point on the calibration curve or the lowest demonstrated level of accep table quantitation (Ref. 4, p. 36). Trace levels below reporting limits are treated as non -detect (Ref. 1, Table 2-3; Ref. 4, p. 269).

**Flagging of data in the data reports (Ref. 4, pp 37 – 86) is inconsistent with statements in the data report (Ref. 4, pp. 34, 68). Generally, the narrative indicates some data should be J-qualified while data sheets did not show a J. Where a conflict appeared, the data was treated as J’d and s ubsequently adjusted as approp riate. Data were adjusted per “Using Qualified Data to Document an Observed Release and Observed Contamination”, to illustrate the relative

increase of hazardous substan ce concentrations of background levels (Ref. 4, pp. 266-283). This is a conservative approach.

**Arsenic and copper results are J’d due to high bias (Ref . 4, p. 34). Background is not adjusted; source/release results are adjusted downward by correction factor of 1.74 for arsenic and 1.22 for copper (Ref. 4, pp. 270, 283). Antimony and lead results are J’d due to uncertain bias. Because matrix spike sample recovery for antimony and lead were low, and because performan ce evaluation sample recovery were “ac tion high” (Ref. 4, p. 34), data was adjusted based on uncertain bias (Ref. 4, pp. 34, 270, 273, 283). Background is adjusted upward and source/release results are adjusted downward by correction factor of 1.98 for antimony and 1.44 for lead (Ref. 4, pp. 270, 283).

BOLD = Observed contamination, which is greater than or equal to 3 times background when detected in background, or greater than background quantitation limit (a ka MRL) and CRQL if background is non-detect (Ref. 1, Table 2-3; Ref. 4, p. 266). Note that source samples were compared to background soil sample in Table 2.

19SD-Hazardous Substances Source No.: 1 (Contaminated soil)

Soil background hazardous substa nce and concentration summary

Level shown without “U” is level detected a bove MRL. J’d levels below MRL are treated as non-detect (Ref. 1, Table 2-3; Ref. 4, p. 269). The number shown in parentheses is the higher of MRL or CRQL.

Antimony non-detect (8.3 UJ, [8.3 U] mg/kg) Arsenic 1.4 J mg/kg Cadmium non-detect (0.69 U mg/kg) Copper non-detect (3.5 U mg/kg) Lead 23 mg/kg Manganese 8.9 mg/kg Mercury non-detect (0.5 U mg/kg) Nickel non-detect (5.5 U mg/kg) Silver non-detect (1.4 U mg/kg) Thallium non-detect (3.5 U mg/kg) Zinc 14 J mg/kg

Source hazardous substances and concen tration summary (estimated con centrations adjusted for bias, where appropriate)

Antimony ranging from 31.8 – 43.4 mg/kg Arsenic ranging from 247 – 517 mg/kg Cadmium ranging from 31 – 42 mg/kg Copper ranging from 210 – 730 mg/kg Lead ranging from 2,430 – 6,944 mg/kg Manganese ranging from 27 – 32 mg/kg Mercury ranging from 2.4 – 35 mg/kg Nickel ranging from 17 – 20 mg/kg Silver ranging from 18 – 43 mg/kg Thallium ranging from 16 – 28 mg/kg Zinc ranging from 4,700 – 7,500 mg/kg

20SD-Hazardous Waste Quantity Source No.: 1 (Contaminated Soil)

2.4.2 Hazardous Waste Quantity

2.4.2.1.1 Hazardous Constituent Quantity — Sufficient evidence does not exist to evaluate Hazardous Constituent Quantity

2.4.2.1.2 Hazardous Waste stream Quantity — Sufficient evidence does not exist to evaluate Hazardous Waste stream Quantity

2.4.2.1.3 Volume —

Sufficient evidence does not exist to evaluate Volume

2.4.2.1.4 Area

Three points were collected in the form er lead chamber / surface impoundment area; the area of contaminated soil is determined to be >0 (Ref. 4, pp. 108, 109, 115-117, 120, 128, 161 173-179, 180-182, 186; Figure 3)

Area assigned value (Ref. 1, Table 2-5)

= A/34,000 = > 0

2.4.2.1.5 Source Hazardous Waste Quantity Value = 

### >0

21SD-Summary

SITE SUMMARY OF SOURCE DESCRIPTIONS

Containment Source Hazardous Waste Quantity Ground Surface Air

No. Value Water Water Gas Particulate

1 >0 NS 10 NS NS

Sum of Source Hazardous Waste Quantity Values = 

### >0

(Rounded to nearest integer, per Ref. 1, Section 2.4.2.2)

22SWOF — Surface Water Overland Flow/Flood Migration Pathway

4.0 SURFACE WATER MIGRATION PATHWAY

4.1 OVERLAND/FLOOD MIGRATION COMPONENT

4.1.1.1 DEFINITION OF HAZARDOUS SU BSTANCE MIGRAT ION PATH FOR

OVERLAND/FLOOD COMPONENT

Source 1 drains northward to Livingston Cr eek. Historically, there could have been several Probable Points of Entry (PPEs) to th e perennial surface water pathway into Livingston Creek (Ref. 4, pp. 18, 228-231); however, the precis e location of former PPEs cannot now be determined because buildings and old impoundments have been removed (Ref. 4, pp. 109, 117) Two of the three source samples (WC-011-SS a nd WC-013-SS) (Ref. 4, pp. 88, 93; Ref. 7, p. 1; Figs. 7, 9) were collected within an area descri bed as a wetland area adjacent to Livingston Creek (Ref. 8, p. 6); however, this area does not meet the 40 CFR 230.3 definition of a wetland due to the lack of hydrophytes, th erefore, the source lies along the overland flow pathway and the PPE is the point where the overland flow ente rs Livingston Creek (Fig. 4). A portion of this source area appeared to consist of low overlapping piles (Ref. 8, p.7) in the wetland area. From Source 1, the overland drainage route flows downgr adient approximately 100 feet northward to Livingston Creek, a perennial wa ter body, marking the start of th e in-water segment of the surface water migration pathway and the 15-mile target distance limit (TDL) (Figs. 1, 4).

Livingston Creek is about 29 feet wide and about 3 feet deep in most locations (Ref. 4, pp. 18, 350). Livingston Creek’s flow be low the Wright Chemical Corp. facility property is slightly greater than 100 cfs, making it a moderate-to-large stream (Ref. 1, Table 4-13; Ref. 4, pp. 18, 250, 259, 260, 262). Below the PPE, Livingston Creek meanders in a generally northerly direction for three miles through extensive wetlan ds, and then flows into the Cape Fear River (Ref. 4, pp. 2, 124; Figs. 1, 6, 8, 9). Livingston Creek flows past landfills associated with the International Paper facility (Figs. 6, 8). There is tidal flow reversal in Livingston Creek (Ref. 10, pp. 1, 2).

Mill Creek is upgradient and to the northeast of Source 1 and enters Livingston Creek downstream of the PPE from the source. Mill Creek flows past the adjacent Hexion property before entering Livingston Creek and does not receive runoff from Source 1 (Fig. 4, 7).

Mill Creek flows from the east, past a road and an iron pipe near the sewer line (as observed during the sample collection event (Ref. 4, pp 88, 92; Figs. 4, 6, 7), and where it is indicated as a pipeline on the USGS topographic map (Fig. 1) then along the northern edge of the Hexion property. The lower part of the source area, th e PPE, and the confluence of Livingston Creek

with Mill Creek has alternatel y been mapped as a pond and a wetland (Ref. 7, p. 1; Figs. 1, 8, 9).

Below the confluence with Livingston Creek, th e Cape Fear flows in an easterly direction for about 6 miles, where the river splits to Lyon Thoroughfare. Lyon Thoroughfare flows easterly and joins with the Black River. The Cape Fear continues to flow in a general southeasterly direction, and 15-mile surface water pathway ends near the confluence of the Black

23River and the Cape Fear. The entire surface water pathway is within the Cape Fear River basin (which includes the Black River), and is a larg e stream-to-river system from the point where Livingston Creek enters the Cape Fear River to the end of the surf ace water pathway (>1000 - 10,000 cfs) (Ref. 1, Table 4-13; Ref. 4, pp. 250 - 265). At the point wh ere Livingston Creek flows into the Cape Fear River, the river is about 300 feet wide and 26 feet deep (Ref. 4, pp. 18, 349).

When some of the fisheries being evaluated are in fresh water and some are in salt water or any are in brackish water, the HRS instructs to use the bioconcen tration factor (BCF) data that yield the higher factor value to assign the bioaccumula tion potential factor va lue to the hazardous substance (Ref. 1, Section 4.1.3.2.1.3). For th is reason, the surface water pathway was researched to determine if any part of the 15- mile surface water pathway is brackish or salt

water.

Lock 1 is about 9 1/2 river miles upstream from where Livingston Creek flows into the Cape Fear River and 37 miles upstream of Wilmington (Ref. 4, pp. 18, 19, 286). The point where Livingston Creek flows into the Cape Fear River is 27 1/2 miles upstream from Wilmington. The point where the Cape Fear joins the Black River is the upstream intrusion limit (200 mg/L chloride), having a 50% chance of being equaled or exceeded in any one year (Ref. 4, pp. 296, 309). Saltwater intrusion may affect wate r quality as far as 20 miles upstream from Wilmington (Ref. 4, p. 300). Therefore, the firs t 10 1/2 miles of the surface water pathway is fresh, and the last 4 1/2 miles of the su rface water pathway is brackish/salt.

24SWOF — Surface Water Overla nd Flow/Flood Migration Pathway

Likelihood of Release

4.1.2.1 LIKELIHOOD OF RELEASE

4.1.2.1.1 OBSERVED RELEASE

Chemical Analysis — Sediment

On April 10, 2007 NC Superfund Section colle cted five background sediment samples from either Mill Creek or Livingston Creek and six (including one duplicate) downstream sediment samples from Livingston Creek, as su mmarized in Tables 3 - 6 below (Fig. 7). Samples were collected according to the Sampling and Analysis Quality Assurance Project Plan (SAP/QAPP) (Ref. 4, pp. 99-104), which was devel oped in accordance w ith the NC Superfund Section Quality Assurance Program Plan (QAPP) and Quality Assurance Standard Operating Procedures (QASOP). The QASOP adopts by reference the Field Branches Quality System and Technical Procedures, U. S. Environmental Prot ection Agency, Region 4. The Program Plan is derived directly from the EPA-Approved NC Department of Environmental and Natural Resources QA Plan for Data, 2004 (Ref. 4, pp. 99- 104). Samples were sh ipped to a Contract Laboratory Program (CLP) laborator y (A4 Scientific) and analyzed for total metals by ICP-AES and cyanide analysis by Statem ent of Work (SOW) ILM05.3 and they were analyzed for pesticides per method SOM01.1 (Ref. 4, pp. 34, 68). A Quality Assurance Chemist with the US EPA Region 4 Science and Ecosystem Support Divi sion reviewed and validated this data for performance according to the Statemen t of Work (Ref. 4, pp. 33, 34, 67-69).

25SWOF — Surface Water Overland Flow/Flood Migration Pathway

Likelihood of Release

Background concentration — Sediment

Only those compounds found in a source and a re lease sample at levels greater than three times background (or greater than background repor ting limits when not detected in background) are listed below in the background data. For the listed compounds not detected in the background, only the Minimum Reporting Lim it (MRL) (Ref. 4, p. 36) and the ContractRequired Quantitation Limit (CRQL) (Ref. 5) valu es are given. When samples are analyzed by the EPA Contract Laboratory Program, the Hazar d Ranking System Final Rule (Ref. 1, Table 2- 3) instructs that when the background concentr ation is not detected or is less than the quantitation limit, an observed re lease is established when the sample measurement equals or exceeds either the Sample Quantitation Limit (SQL), or if this can not be determined, the Contract-Required Quantitation Li mit (CRQL) (Ref. 1, Table 2-3; Ref. 4, p. 266; Ref. 5). For inorganic compounds, Reference 5 provides the Contract Require d Quantitation Limit (CRQL) (Ref. 1, Section 1.1, see definition for CRQL).

Table 3. Background Sediment Samples Sample

number Date; time Description

WC-001-SD 4/10/07;1250 (Ref. 4, pp. 35, 70, 88, 91, 95, 97; Fig. 7) Grab sediment sample upstream of Old Highway 87 on Livingston Creek; background sample (MS/MSD); Tan sand, no layer or organics (Ref. 4, pp. 88, 91)

WC-002-SD 4/10/07; 1310 (Ref. 4, pp, 35, 70, 88, 92, 95, 97; Fig. 7) Grab sediment sample downstream of railroad on Livingston Creek; background sample (Ref. 4, pp. 88, 92)

WC-008-SD 4/10/07; 1145 (Ref. 4, pp, 35, 70, 87, 95, 97; Fig. 7) Grab sediment sample downstream of Neils Eddy Road on Mill Creek; background sample (Ref. 4, pp. 87, 90)

WC-009-SD 4/10/07; 1120 (Ref. 4, pp, 35, 70, 87, 90, 95; Fig. 7) Grab sediment sample upstream of iron pipe near sewerline and roads on Mill Creek; background sample (Ref. 4, pp. 87, 90)

WC-010-SD 4/10/07;1515 (Ref. 4, pp, 35, 70, 88, 93, 95, 97; Fig. 7) Grab sediment sample upstream of confluence of Mill Creek and Livingston Creek on Mill Creek; ba ckground/attribution (Ref. 4, pp. 88, 93; Ref. 8, p. 1)

2627 SWOF — Surface Water Overla nd Flow/Flood Migration Pathway

Likelihood of Release

Table 4. Background Sediment Sample Results

CRQL WC-001-SD WC-002-SD WC-008-SD WC-009-SD WC-010-SD Analyte (mg/kg)

Ref. 5 Ref. 4, pp. 36,

37 Ref. 4, pp. 36, 39 Ref. 4, pp. 36, 51 Ref. 4, pp. 36, 53 Ref. 4, pp. 36, 55

bkg bkg bkg bkg bkg

Arsenic** 1 1.5 U 3.7 U 1.6 U 2.4 U 2.4 J* (1.7)

Cadmium 0.5 0.77 U 1.2 J (1.9 U) 0.78 U 1.2 U 0.86 U Copper** 2.5 29 J 63 J 10 J 13 J 8.6 J

Lead** 1 3.7 J [5.3] 26 J [37] 2.4 J [3.5] 5.7 J [8.2] 10 J

Zinc 6 18J 130 5.4 J 21 J 38 J = an estimated quantity “U” indicates non-detect, and the number adjacent to U is the MRL. [ ] provides the adjusted valu e for the estimated (J’d) value as adjusted for bias (Ref. 4, pp. 266 - 283).

*( ) = Minimum Reporting Limit (MRL) is shown in parentheses when a trace value is reported below the MRL. The MRL is the analyte concentration whic h corresponds to the lowest quantitative point on the

calibration curve or the lowest demonstrated level of acceptable quantitation (Ref. 4, p. 36).

**Note that the flagging of some data in the data tables (Ref. 4, pp 37 – 86) is inconsistent with statements at beginning of the data report (Ref. 4, pp. 34, 68). Generally, the narrative indicates some data should have been J-qualified while data sheets did not show a J. Where a conflict appeared, the data was treated as J’d and subsequently adjusted as indicated.

**Arsenic and copper results are J’d due to high bias (Ref. 4, p. 34). Background is not adjusted; source/release results are adjusted downward by correc tion factor of 1.74 for arsenic and 1.22 for copper (Ref. 4, pp. 270, 283).

** Antimony and lead results are J’d due to uncertain bi as. Because matrix spik e sample recovery for antimony and lead were low, and because performan ce evaluation sample recovery were “action high” (Ref. 4, p. 34), data was adjusted base on uncertain bias (Ref. 4, pp. 34, 270, 273, 283). Background is adjusted upward and source/release results are adju sted downward by correction factor of 1.98 for antimony and 1.44 for lead (Ref. 4, pp. 270, 283).SWOF — Surface Water Overla nd Flow/Flood Migration Pathway

Likelihood of Release

Contaminated Samples — Sediment

The following sediment samples were collected on April 10, 2007. .

Table 5. Sediment Samples

Distance from PPE (ft.) Fig. 7 Description

WC003-SD 250 4/10/07; 1440 (Ref. 4, pp, 35, 70, 88, 93, 95, 97; Fig. 7) Grab sediment sample upstream of confluence of Livingston Creek and Mill Creek; sample collected at bend, 0 – 9”, sandy material, all tan (Ref. 4, pp. 88, 93)

WC013-SD* Same as above 4/10/07; 1440 (Ref. 4, pp, 35, 70, 88, 93, 96, 98; Fig. 7) Duplicate of WC-003-SD . See discussion below regarding WC-103-SD / WC-013-SD (Ref. 4, pp. 88, 93)

WC004-SD

750 4/10/07; 1540 (Ref. 4, pp, 35, 70, 88, 93, 95, 97; Fig. 7) Grab sediment sample downstream of confluence of Livingston Creek and Mill Creek, approximately 75 yards downstream of confluence. Grey silty sand, 0 – 6” (Ref. 4, pp. 88, 93)

WC005-SD 2650 4/10/07; 1055 (Ref. 4, pp, 35, 70, 87, 90, 95, 97; Fig. 7) Grab sediment sample 30’ upstream of second pipeline (36” iron). Little organic on top, mix of sand, clay and organics. (Ref. 4, pp. 87, 90)

WC006-SD 2800 4/10/07; 1040 (Ref. 4, pp, 35, 70, 87, 89, 95, 97; Fig. 7) Grab sediment sample collected 50’ downstream of sewer pipeline, sandy clay material under 2” organic layer. (Ref. 4, pp. 87, 89)

WC007-SD 4000 4/10/07; 1010 (Ref. 4, pp, 35, 70, 87, 89, 95, 97; Fig. 77) Grab sediment sample on Livingston Creek; release sample 0.1 mile wetland frontage, upstream of wooden pier. 0 – 6”, grey clay with tan sand (Ref. 4, pp. 87, 89)

* Note that field log notes di scuss the collection of WC-003-SD (Ref. 4, pp. 88, 93) but do not specifically discuss the collecti on of the duplicate WC-103-SD. Ho wever, the sample plan (Ref. 4, p. 102) lists sample WC-103-SD and the chain of custody shows that WC-103-SD was sample collected at same time as WA-003-SD (Ref. 4, p p. 96, 98). Note also that the laboratory report did not contain results for WC-103-SD, but did s how results for WC-013-SD, a sample not listed on the chain of custody. WC-013-SD (as reporte d by the lab), shows the same date, time and CLP sample ID number as that indicated for WC-103-SD on the chain of custody (Ref. 4, pp. 35, 65, 66, 70, 86).

28SWOF — Surface Water Overland Flow/Flood Migration Pathway

Likelihood of Release

Table 6. Sediment Sample Results

WC-003-

SD WC-013-

SD mg/kg CRQL WC-004-

SD WC-005-

SD WC-006-

SD WC-007-

SD

Reference Ref. 5 (Ref. 4, pp. 34, 36, 41,) (Ref. 4, pp.34, 36, 65, 66) (Ref. 4, pp. 34, 36, 43) (Ref. 4, pp. 34, 36, 45) (Ref. 4, pp. 34, 36, 47) (Ref. 4, pp. 34, 36, 49) Sample

purpose release release/dup re lease release release release

Arsenic** 1 31 J [17.8] 29 J [16.6] 1.3 U 2.9 J (3.1 U) 320 J [183.9] 0.95 J (1.3 U)

Cadmium 0.5 3.5 3.6 0.30 U, J 1.1 U.J 2.4 U, J 0.28J (0.65 U)

Copper** 2.5 190 J [155] 150 J [122] 5.4J 73 J [59] 770 J [631] 22

Lead 1 520 J** [360] 430 J** [300] 8.2 J** [5.7] 130 J** [90] 1200 J** [830] 25 J** [17]

Zinc 6 660 780 5.9J 160 380 36

J = estimated quantity “U” indicates non-detect, and the number adjacent to U is the MRL. [ ] = value adjusted for bias (Ref. 4, pp. 266 - 283).

*( ) = Minimum Reporting Limit (MRL) is shown in parentheses when a trace value is reported below the MRL. When an estimated level is reported belo w Contract Required Reporting Limit (CRQL) / MRL, this value is considered non-detect (Ref. 1, Table 2-3)

**Note that the flagging of some data in the data tables (Ref. 4, pp 37 – 86) is inconsistent with statements at beginning of the data report (Ref. 4, pp. 34, 68). Generally, the narrative indicates some data should have been J-qualified while data sheets did not show a J. Where a conflict appeared, the data was treated as J’d and subsequently adjusted as indicated.

**Arsenic and copper results are J’d due to high bias (Ref. 4, p. 34). Background is not adjusted; source/release results are adjusted downward by correc tion factor of 1.74 for arsenic and 1.22 for copper (Ref. 4, pp. 270, 283).

** Lead results are J’d due to uncertain bias. Becau se matrix spike sample recovery for lead was low, and because performance evaluation sample recovery we re “action high” (Ref. 4, p. 34), data was adjusted base on uncertain bias (Ref. 4, pp. 34, 270, 273, 283). Background is adjusted upward and source/release results are adjusted downward by correc tion factor of 1.44 for lead (Ref. 4, pp. 270, 283).

BOLD indicates an observed release An observed release must be either greater than background CRQL / MRL (when non-detect) or three times the level detected in background (Ref. 1, Table 2-3; Ref. 4, pp. 266 - 283). To determine an Observed Release, the highest detect / CRQL of the five background sediment samples was used.

29SWOF — Surface Water Overland Flow/Flood Migration Pathway

Likelihood of Release

Background sediment concentration summary (highest detected level, or the highest quantitation limit of the five background samples)

Arsenic 3.7 U mg/kg Cadmium 1.9 U mg/kg Copper 63 J mg/kg Lead 37 mg/kg (adjusted upward due to uncertain bias) Zinc 130 mg/kg

Hazardous substances in observed release to sediment summary.

Sample WC-003-SD and its duplicate WC-013-SD serve to document the observed release of arsenic, cadmium, copper, lead, an d zinc into the fishery. While samples just downstream of the site (WC-004-SD and WC-005-SD) did not show site contaminan ts, sample WC-006-SD showed higher levels of site contaminants. Given the passage of time since operations ceased, it can be anticipated that various storm and erosion even ts could cause uneven di stribution and migration

of contaminants downstream from the source.

Arsenic 320 mg / kg Cadmium 3.6 mg/kg Copper 770 mg/kg Lead 830 mg/kg Zinc 780 mg/kg

30SWOF — Surface Water Overland Flow/Flood Migration Pathway

Likelihood of Release

Further discussion:

There appears to be some pesticide contamination at this site; however, this information was not used to produce the site score. A nearby upgradient faci lity manufactured chlorinated pesticides (Ref. 9, pp. 1-12).

4.1.2.1.1.1 ATTRIBUTION

The Wright Chemical Corp site was a fertiliz er and sulfuric acid manufacturing facility founded in 1883 (Ref. 4 pp. 397, 401). The original Acme plant was a lead-lined “chamberprocess” plant that thermally extracted sulfur from pyrite (Ref. 4 pp. 109). Sanborn Fire Insurance Maps dated from 1898 and 1910 confirm that “Lead Acid Chambers” were previously present on the property where Source 1 has been identified (Ref. 4 pp. 173-179; Fig. 3).

Denuded, mag enta-colored soil characteristic of former lead chamber sulfuric acid manufacturing facilities (Ref. 4 pp. 214-215) has been documented in the vicinity of the former process areas on the property (Ref. 8, pp. 1-8). Th is magenta colored soil t ypically contains lead in the 4,000 – 20,000 mg/kg range and depending on th e raw materials used in the processes, it

can also contain substantial amounts of other meta ls and contaminants (Ref. 4 p. 215). Source 1

has been documented to contain elevated concen trations of metals including arsenic, cadmium, copper, lead, and zinc (see Table 2 of this HRS documentation record) (Ref. 4, pp. 34, 36, 57-59, 61-63; Fig. 4).

Source 1 drains north, downgradient into Livingston Creek (Figs. 1, 4). Sediment samples taken from Livingston Creek directly downgradient from source 1 show elevated

concentrations of metals anal ogous to those found in source 1 (R ef. 4, pp. 35-56, 87-93; Fig. 7).

Additionally, sediment samples WC-011-SS a nd WC-013-SS have been documented as being located in a wetland contiguous to Livi ngston Creek (Ref. 8, p. 6, Fig. 4). Since samples

WC-011-SS and WC-013-SS are located in a wetland contiguous with Livingston Creek, evidence of direct deposition of hazardous chemi cals directly into the Creek from source 1 is

present.

There are three current/former facilities/sites that are upgradient from this site – Hexion, Kaiser Agricultural, and Kaiser Acme Farm arket (Ref. 4, pp. 108, 109-110, 117; Ref. 9, 1-12). There are two nearby facilities/sites that are downgradient from Wr ight Chemical – International Paper (aka Federal Paperboard) and Holtrachem (Ref. 4, p. 3, Figs. 5, 6). The neighboring Hexion facility was at one time owned and operate d by the Wright Chemical Corp. The history of chemical manufacturing on this adjacent 20-acre Hexion parcel included formaldehyde, hexamine, chloropicrin, silicon compounds and pha rmaceuticals. There is no history of work with metals (Ref. 4, pp. 9, 129, 397-404). One sample (WC-010-SD; Tables 3, 4) was collected downgradient of Hexion and up gradient from Li vingston Creek. This sample documents any

31impact to Mill Creek that may have occurred from runoff from the Hexion site prior to it entering Livingston Creek.

The archived Kaiser Agricultu ral Chemical site (NCD 980 84 2 470) adjacent to and south of the lead chamber properties was once part of Acme Chemical and was owned by Wright Chemical. This parcel housed th e fertilizer portion of the operation, it was investigated under CERCLA, and was archived from CERCLA in 1989 (Ref, 4, p. 110, 111). The former Kaiser Acme Farmarket (NCD 980 557 847) pest icide facility is about 1⁄4 mile to the south. This facility was associated with chlorinated pesticide ma nufacturing from 1967 – 1971 and subsequently for pesticide retail sales. There is no evidence it had metal contamination (Ref. 9, pp. 1-12).

To the north and across Livingston Creek is the 978-acre parcel ow ned by Federal Paper Board Co., Inc. (aka Internati onal Paper) (Ref. 4, p. 452.3; Fig. 5) . Adjacent to and east of Federal Paper Board, bordering the Cape Fear River is the former Holtrachem (aka LCP Chemicals; Honeywell; Allied Signal) mercury cell chlor-alkali plant site (NCD 991 278 631), currently owned by Honeywell International (Ref. 4, pp. 452.4, 452.5; Fig. 6). Both of these sites are downgradient from the Wright Chemical Corp site. There is some flow reversal on Livingston Creek (Ref. 10, pp. 1, 2); however, neither the Holtrachem nor th e Internati onal Paper

site are associated with any lead, arsenic, cadmium, copper, or zinc contamination (Ref. 8, p. 2). Holtrachem has high contamination with mercury and PCBs (Ref. 8, p. 2).

4.1.2.1.2 POTENTIAL TO RELEASE TO SURFACE WATER—

Not scored because observed release to surface water sediment documented by chemical analysis

========================= ==================== ================== Surface Water Sediment Observed Release Factor Value— 550 ( Ref. 1, Section 4.1.2.1.1)

32SWOF Human Food Chain Threat

4.1.3 HUMAN FOOD CHAIN THREAT

The human food chain threat is evaluated based on three factor categories: likelihood of release, waste characteristics , and targets.

4.1.3.1 HUMAN FOOD CHAIN THREAT-LIKELIHOOD OF RELEASE

The human food chain threat likelihood of release is the same as that for the drinking water threat (Ref. 1, Section 4.1.3.1) . Level II contamination in Livingston Creek from the PPE downstream 2800 feet to Sample WC-006-SD has b een documented as a part of a fishery. (Ref. 4, pp. 35, 70, 87, 531-533, Fig. 7).



### 550

4.1.3.2 HUMAN FOOD CHAIN THREAT -WASTE CHARACTERISTICS

The wast e characteristics f actor category for each watershe d is based on two factors: toxicity/ persistence / bioaccumulation and hazardous waste quantity (Ref. 1, Section 4.1.3.2).

4.1.3.2.1 Toxicity/Persistence/Bioaccumulation

The HRS instructs to evaluate the wast e characteristics factor category based on two factors: toxicity/ persistence and hazardous waste quantity. And, to evaluate only those hazardous substances that are available to migrate from th e sources at the property to surface water in the

watershed via the overland/flood hazardous substa nce migration path for the watershed. Such

hazardous substances include hazardous substances that meet the criteria for an observed release to surface water in the watershed, and all hazardous substances associated with a source that has

a surface water containment factor value greater than 0 fo r the watershed (Ref. 1, Section 4.1.2.2,

also see sections 2.2.2

, 2.2.3

, 4.1.2.1.2.1.1 , and 4.1.2.1.2.2.1 ). Tables 7 and 8 of this HRS documentation record present those substances documented in the observed release to the fishery, and those substances documented in the source with a containment factor value greater

than 0.

As discu ssed above, Livingston Creek (3 miles) and the first 7 1⁄2 miles in the Cape Fear River is fresh, and the last 4 1/2 miles of the surface water pathway is brackish/salt. (See discussion in 4.1.1.1 above; Ref. 4, pp. 296, 300, 309).

The Hazard Ranking System (HRS) instructs th at if bioconcentration factor (BCF) data

are available for both fresh water and salt water for the hazardous substan ce, use the BCF data that corresponds to the type of water body (that is, fresh water or salt water) in which the fisheries are located to assign the bioaccumula tion potential factor value to the hazardous substance. If, however, some of the fisheries being evaluated are in fresh water and some are in salt water, or if any are in brackish water, use th e BCF data that yield th e higher factor value to

33SWOF – Human Food Chain Threat

assign the bioaccumulation potential factor valu e to the hazardous subs tance (Ref. 1, Section 4.1.3.2.1.3). Because the fishery is located in fr esh water, only fresh water bioaccumulation values will be used as per the HRS.

Table 7. Source 1 Contaminants Documented in Observed Release to Sediment in the Fishery

PF # Hazardous

Substance Tox. Factor

value BPFV*

Fresh

Food** BPFV*

Salt

Food** T/P value (Ref. 1, Table 4-12) (fresh) (Ref. 1, Table 4-16)

T/P/BPFV T/P/BPFV (salt) (Ref. 1,

Table 4-16)

Arsenic 10,000 1 5 500 10,000 5 x 10 E4 5 x 10 E6

Cadmium 10,000 1 5,000 50,000 10,000 5 x 10 E7 5 x 10 E8 Copper 0 1 500 50,000 0 0 0

Lead 10,000 1 5 5,000 10,000 5 x 10 E4 5 x 10 E7

Zinc 10 1 5 50,000 10 50 5 x 10 E5

Table 8. Source 1 Contaminants Documented in Source with Containm ent Factor of 10, not documented in Observed Release to Fishery Sediment

Hazardous

Substance Tox. Factor

value PF # BPFV*

Fresh

Food** BPFV*

Salt

Food** T/P value (Ref. 1, Table 4-12) T/P/BPFV (fresh) (Ref. 1, Table 4-16) T/P/BPFV (salt) (Ref. 1,

Table 4-16) Antimony 10,000 1 5 5 10,000 5 x 10 E4 5 x 10 E4 Manganese 10,000 1 50,000 50,000 10,000 5 x 10 E8 5 x 10 E8 Mercury 10,000 1 50,000 50,000 10,000 5 x 10 E8 5 x 10 E8

N ickel 10,000 1 0.5 500 10,000 5 x 10 E3 5 x 10 E6

Silver 100 1 50 50,000 100 5 x 10 E3 5 x 10 E6

Thallium 100 1 500 50 100 5 x 10 E4 5 x 10 E3

T/P/BPFV = Toxicity/Persistence/Bioaccumulation Potential Factor (Ref . 1, Table 4-16) **Ref. 2, Appendix BI, pp. 1-15

BPFV = Bioaccumulation Potential Factor Value

# PF = Persistence Factor Value, Ref. 1, Section 4.1.3.2.1.2; Ref. 2 *Ref. 1, Section 4.1.3.2.1.3; Ref. 2.

Of those contaminants documented in the observed release to the fishery, cadmium has the highest T/P/BPFV freshwater value. Of those contaminants documented in the source but not in fishery sediment, manganese and mercury have the highest freshwater values. Manganease and mercury were used to assign th e toxicity/persistence/bioaccumulation factor value as per Section 4.1.3.2.1.4 of the HRS.

========================= ==================== ==================

Toxicity/Persistence/Bioaccumulation Factor Value: = 

### 5 x 10 8

34SWOF – Human Food Chain Threat

4.1.3.2.2 Hazardous Waste Quantity

HRS (Ref. 1), Section 4.1.3.2.2 inst ructs that if any target for that migration pathway is subject to Level I or Level II conc entrations, assign either the valu e from Table 2-6 or a value of 100, whichever is greater, as the hazardous waste quantity factor value for that pathway. (Ref. 1, Section 2.4.2.2)

Hazardous Waste Quantity Factor Value = 

### 100

4.1.3.2.3 Human Food Chain Threat Waste Char acteristics Factor Category Value:

Toxicity/Persistence Value = 10,000 Bioaccumulation Potential Factor Value = 50,000

Toxicity/Persistence Value x Hazard ous Waste Quantity Factor Value: 10,000 x 100 = 1,000,000 (1 x 10 6 )

(Toxicity/Persistence x Hazardous Waste Quantity) x Bioaccumulation Potential

Value:

(1 x 10 6 ) x 50,000 = 5 x 10 10

========================= ==================== ================== Human Food Chain Hazardous Waste Quantity Assigned Value/

Human Food Chain Waste Characteri stics Factor Category Value 

### 320
(Ref. 1, Table 2 - 7; Sections 4.1.3.2.3 and 2.4.3.1):

35SWOF – Human Food Chain Threat

4.1.3.3 HUMAN FOOD CHAIN THREAT - TARGETS

Actual Human Food Chain Contamination

Observed Release to Surface water sediment (Level II) was documented in Section

4.1.3.1.

Livingston Creek, from WC- 001-SD upstream of Old Highway 87 until its confluence with the Cape Fear River is a fishery. Brim, ba ss and catfish are caught in the creek, and catches are cooked and consumed on the creek banks (Ref. 4, pp. 88, 91, 531 – 533). The Cape Fear River is an important fishery (Ref. 4, pp. 291 – 293; 490 – 502; 531 -- 533). Atlantic Sturgeon, Striped Bass and American Shad catches are thr ee of the seven anadromous species found in the Cape Fear River system, along with several nonn ative species (Ref. 4, pp. 490 - 502). The Cape Fear River is a commercial fishery (Ref. 4, pp. 289, 291, 293). The estimated 1981 harvest was 1.3 million pounds for the entire basin downstrea m of Lock 1 (Ref. 4, p. 292); however, the fishery has experienced a decline (Ref. 4, 492). Commercial off-shore sh ad fishing has been phased out, making the inshore Cape Fear River shad fishery even more important (Ref. 4, p. 492). The Atlantic Sturgeon is a threatened species and the shor tnose sturgeon is an endangered species; there is a reproducing popul ation of these two species in this drainage basin (Ref. 4, p. 495).

Researchers at the University of North Caro lina Wilmington's Center for Marine Science performed a pilot study in 2003-2004 to assess metals and organic contaminant concentrations at three areas in the Lower Cape Fear River sy stem (Ref. 4, p. 476). One of these areas was Livingston Creek, about 40 meters upstream of th e confluence with the Ca pe Fear River (LVC) (Ref. 4, pp. 475, 476; Fig. 6). The clam and bottom-f eeding fish tissue concentrations of arsenic, cadmium, mercury, selenium, and Dieldrin exceeded their respective recommended concentration range, indicating potential human health probl ems (Ref. 4, pp. 476, 480 -- 484).

4.1.3.3.1 Food Chain individual (Ref. 1, Section 4.1.3.3.1)

Level II contamination in Livingston Creek fromthe PPE downstream 2800 feet to Sample WC006-SD has been documented as a part of a fishery. (Ref. 4, pp. 35, 70, 87, 531-533, Fig. 7).

"If any fishery (or portion of a fishery) is subject to Level II concentrations, assign a

value of 45.

====================================================== ========= Food Chain Individual Factor Value = 45

36SWOF – Human Food Chain Threat

4.1.3.3.2 Population

4.1.3.3.2.1 Level I Concentrations -- not scored

4.1.3.3.2.2 Level II Concentrations

Arsenic, cadmium, copper, lead, and zinc contamination have been documented in source 1 and in sediment in the fishery. The le vel of contaminants is summarized below:

mg/kg WC-003-SD WC-013-SD WC-006-SD

Arsenic 31 J [17.8] 29 J [16.6] 320 J [183.9]

Cadmium 3.5 3.6 2.4 U, J
Copper 190 J [155] 150 J [122] 770 J [631]

Lead 520 J** [360] 430 J** [300] 1200 J** [830]

Zinc 660 780 380

Given the active fishing occurr ing in Livingston Creek (Ref. 4, p. 531) >0 pounds of fish are caught in Livingston Creek and consumed. A Food Chain Population value of 0.03 is assigned (Ref. 1, Table 4-18).

Level II Concentrations Factor Value = 0.0 3

4.1.3.3.2.3 Potential Human Food Chain Contamination – not scored

4.1.3.3.3 Calculation of Human Food chain threat - targets factor category value (Ref. 1, Section 4.1.3.3.3)

Human food chain threat-targe ts factor category value =

Human Food Chain Individual + Level II concentrations =

45 + (0.03) = 45.03

4.1.3.4 Calculation of human fo od chain threat score

Likelihood of release x waste char acteristics x targets / 82,500 =

550 x 320 x 45.03 / 82,500 = 96.06

========================= ==================== ==================

Human Food Chain Threat Score = 96.06

3738 SWOF/Environment

4.1.4 ENVIRONMENTAL THREAT

Even though there are extens ive wetlands along the surface water pathway (Ref. 7, p. 1, Fig. 9), the environmental threat was not scored because it would have had a minimal additional impact on the surface water pathway score.

### Table 4-1 Surface Water Overland/Flood Migration Component Scoresheet

Human Food Chain Threat
Maximum Value Value Assigned Likelihood of Release: 550 550

Waste Characteristics:

Toxicity/Persistence/Bioaccumulation (a) 5 x 10 8

Hazardous Waste Quantity (a) 100

Waste Characteristics 1,000 320

Targets: Food Chain Individual Factor Value 50 45

Level I Concentrations (b)

Level II Concentrations (b) 0.03

Potential Human Food Chain Contamination (b)

Population (Level I + Level II + Potential) (b) 45.03

Human Food Chain Threat Score: [550 x 320 x 45.03] / 82,500 = 100 96.06

(a)Maximum value applies to waste characteristics category (b)Maximum value not applicable

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